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liabilities on certain joint returns filed with James S. Vuxta.1
After concessions,2 the issue for decision is whether respondent
abused his discretion in denying petitioner’s request for relief
under section 6015(f) for taxable years 1989, 1990, and 1991.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
This case was submitted fully stipulated pursuant to Rule
122(a). All stipulated facts are found accordingly. The
attached exhibits are incorporated by reference. Petitioner
1 Petitioner contends that for the taxable years 1989
through 1992, the unpaid tax liabilities total $42,329.35,
including interest and penalties. Respondent contends that for
the same taxable years the unpaid tax liabilities total
$18,617.38, which amount does not include interest, penalties,
and payments after Mar. 14, 2003.
2 Petitioner requested relief from joint and several
liability for the taxable years 1988 through 1997. After
respondent denied her request, petitioner commenced an action for
determination of relief only with respect to taxable years 1989,
1990, 1991, and 1992 and only under sec. 6015(f). Consequently,
we conclude that petitioner has abandoned any contention with
respect to the other taxable years and to relief under sec.
6015(b) and (c). See Butler v. Commissioner, 114 T.C. 276, 278
n.2 (2000). Respondent concedes that the issue of relief with
respect to the unpaid tax liability for 1992 is moot, because the
period of limitations on collection has expired under sec. 6502
and was not tolled during the pendency of the bankruptcy
proceeding described infra.
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Last modified: May 25, 2011